.... Stefan Rydin replies

31 October 2002




Barry Wood is correct that the results were a shock and we therefore considered that it was important for the leather industry to know about the results in Denmark. We were surprised to find that 15 out of 43 (35%) leather samples in the Danish market contained hexavalent chromium. I am, however, happy to read that BLC rarely find hexavalent chromium in the routine tests performed at BLC. It clearly shows that it is possible to produce leather without hexavalent chromium. The differences between our results and the results at BLC may, as we mention in the article, be that samples sent to BLC for analyses come from producers needing a certificate and the producers are, therefore, aware of the problem and have taken measures to avoid the hexavalent chromium in the product (and as Barry Wood reports have been successful in this matter). Our investigation was made on leather products which were randomly bought in the Copenhagen area and should, therefore, represent a mixture of all leather products in the market. I assume that this explains the difference in the results obtained by BLC and us. Our analyses were performed by LGR in Germany, which has major experience in carrying out the leather analyses. I am convinced that BLC and LGR has the same ability to carry out these analyses and that we would have received the same results if the samples had been sent to BLC. We are aware of all the discussions on the accuracy of the test methods. However, since this was an investigation for the Danish EPA, we were using an official standard test method for the analyses. The reason for using the German DIN-method is given in the article. The same detection limit also exists for the other three official test methods we mention in the article. We could not use a draft method for this investigation, mentioned by Barry Wood, when there are actually several official test methods available. The goal with the Danish investigation was to investigate whether hexavalent chromium in leather products was present in the Danish market or not. The number of samples was, therefore, limited and the investigation does not conclude that any leather article should be more likely to contain hexavalent chromium than others. We conclude that the number of leather articles containing hexavalent chromium was unexpected, especially taking into consideration that hexavalent chromium in the leather products can be avoided (which can be seen from the leather testing at BLC). We were especially concerned to find hexavalent chrome in baby shoes. As Barry Wood mentions, babies put their shoes into their mouths and are, therefore, highly exposed to eventual allergic substances in the shoes. I have a two year old baby and it was, therefore, of huge concern to me to find hexavalent chromium in a baby shoe (I am sure that all parents with small children would feel the same). The results were discussed with the Danish EPA and medical experts in chromium allergy. The medical experts indicated that they believe that chrome allergy also may be provoked by high concentrations of trivalent chrome. It was, therefore, decided to make the migration test according to the EU standard for toys. I believe that baby shoes should comply with this standard, since babies do suck their shoes. As a parent, I do not think that babies should be exposed to metals in concentrations above the limits in the toy directive. The ICP-AES is measuring the total content of chromium as you mention. This is also indicated in table two, which states Cr (when we talk about hexavalent chromium it is clearly mentioned). I am sorry if someone may have misunderstood this. The article does not recommend that 'importers… should check the content of dangerous chromium compounds'. This is a quotation from a statement made by Steen Gade, who is the director of the Danish EPA (I assume that the statement only relates to hexavalent chromium and that the word compounds actually should have been compound in English). I believe you will have the same opinion when you read the whole statement published in our article and not only one sentence. Barry Wood also mentions that the Official Journal of the European Commission allows the addition of chromium (III) sulfate as an additive to food supplements. Chrome is a necessary micro-nutrient for humans and animals. However, the chromium should only be present in very low concentrations and higher concentrations will have negative effects on the health. I assume that it is not the policy of BLC that it is safe for animals and humans to eat chromium independently of the concentration. Finally I am happy that you believe that tanners should take a responsible view to producing leather that is safe for the consumer. We also believe that tanners should be responsible and it is our opinion that in general they are very responsible and make strong efforts to produce safe leather. It is, therefore, according to us, important for the leather industry to know about any problems relating to their products so they can carry out the necessary actions and controls. In this connection, I would like to draw your attention to the final part of the article, describing some of the follow-up activities in Denmark. As you can see in the article, research work has started to provide information of which levels of hexavalent chromium in leather that may provoke allergy (or if high concentrations of extracted trivalent chromium may give rise to allergy as indicated by medical experts). I think this work is very important and it will be of great interest for the leather industry to receive this information. Today, we do not know which concentration of hexavalent chromium in leather may be giving rise to allergy. We only know that the problem exists since, as mentioned in the article, there are 200-300 new cases of severe chromium allergy every year in Denmark due to footwear. We, therefore, believe that the leather industry should follow the development of the ongoing Danish study with a positive interest, since the ultimate objective for everyone is the production of safe leather products. Stefan Rydin



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